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1. Within 90 days of the permanent retirement of any production well (not including <br />temporary suspension as discussed in Section G), the permittee shall notify the Director of <br />its intention to plug and abandon the well in accordance with Section II E (1) of this permit <br />or to convert the well to a monitoring well (conversion notice). <br />2. If the permittee intends to convert the well to a monitoring well, a plan for the recompletion <br />of the well as a monitoring well shall be submitted to the Director at the same time that the <br />permittee notifies the Director of its intent to convert the production well to a monitoring <br />well. <br />3. The permittee shall complete the conversion of the production well to a monitoring well <br />within 120 days of the date of the conversion notice, unless otherwise approved by the <br />Director. <br />4. Water level monitoring in any converted dissolution aquifer monitoring wells shall be as <br />specified for dissolution surface monitoring wells in the Water Monitoring Plan (Appendix <br />I). <br />If water-level monitoring indicates that the Injection Zone outside of the Injection Interval is being <br />pressurized, corrective action is required as specified in Part II D (1) (k) of this Permit. <br />• The following section, Part II D(1)(k), is proposed to be added to the Permit: <br />(k) Corrective Measures in Response to Dissolution Surface Monitoring: The following <br />corrective action measures will be implemented when a dissolution aquifer monitoring well <br />indicates an increase in water level of 20 feet or more over the previous 6 month average level <br />(trigger level). <br />1. EPA will be notified within one business day of the pressure increase. <br />2. The permittee shall initiate a technical review of operating data from the surrounding wells <br />to assess which well is most likely to be the source. The analysis may include well operating <br />pressures, available brine chemistry data, N2 gas blanket data, and other data. The <br />permittee must conduct such tests as may be necessary to assist in the identification of the <br />source well. <br />3. Within 5 days of identifying atrigger-level pressure increase, the permittee will take such <br />action as maybe necessary to stabilize and shut-in the well determined to be the most likely <br />source of the pressurization (source well). The source well will be stabilized prior to shut-in <br />to prevent plugging or other impacts to the well that would compromise its future <br />operational ability. <br />4. Should the source well shut-in not result in a pressure decrease in the dissolution aquifer, <br />American Soda will continue well analyses and shut-in additional surrounding wells until <br />such time as the pressure reduces to less than the trigger level. <br />5. American Soda shall provide a summary report of the findings and the responses taken to <br />correct the cause of the increased water level to EPA within 14 days after the pressure <br />decreases below the trigger level. <br />6. A specific corrective action and/or cavity operation plan shall be filed with the Director <br />prior to returning any the source well(s) to operation. Injection operations shall not resume <br />in any source well until the Director approves the corrective action and/or cavity operation <br />plan, and provides written authorization to resume injection. <br />FINAL Addendum to SOB For Modification No. 9, UIC Area Permit No. C030858-00000 Page 9 of 29 <br />